Battery Stewardship Renewal Plan for Manitoba - Version 4 - Province of Manitoba
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Battery Stewardship Renewal Plan for Manitoba – Version 4 2017 – 2021 June 12, 2017 Submitted by: Delphine Lagourgue Director, Central Canada Call2Recycle Canada, Inc. 5140 Yonge Street, #1570 Toronto, ON M2N 6L7 dlagourgue@call2recycle.ca http://www.call2recycle.ca Submitted to: Manitoba Sustainable Development
Table of Contents
Executive Summary ............................................................................................................ 2
1. Plan Submission.............................................................................................................. 3
2. Call2Recycle Overview ................................................................................................... 3
3. Collection System and Consumer Access ....................................................................... 4
4. Transportation and Sorting .............................................................................................. 9
5. Processing of Products ................................................................................................... 9
6. Consumer Awareness - Education and Outreach ......................................................... 11
7. Funding Structure .......................................................................................................... 13
8. Management of Environmental Impacts ........................................................................ 14
9. Dispute Resolution ........................................................................................................ 15
10. Performance Measurement and Targets ..................................................................... 16
11. Stakeholder Consultation ............................................................................................ 19
12. Appendices ................................................................................................................. 20
Appendix A: Glossary .................................................................................................. 20
Appendix B: Physical Flow Chart ................................................................................. 21
Appendix C: Highlights from Ipsos Reid Research - Oct 2015 ..................................... 22
Appendix E: Summary of Performance Measures ....................................................... 27
Appendix F: Stewardship Plan Reference ................................................................... 28
Appendix G: Stakeholder Consultation FAQs .............................................................. 34
Executive Summary Call2Recycle Canada, Inc. (Call2Recycle®) is a non-profit organization created and funded by battery and product manufacturers committed to responsible recycling. The stewardship program has been operating in Canada since 1997 collecting and recycling primary and rechargeable batteries nationally. In 2011 Call2Recycle was appointed by the Manitoba Government as the agent for battery stewardship in the province. Since the program was officially launched, Call2Recycle has collected more than 325,000 kg of batteries in the province and diverted them from the waste stream. The program has experienced steady growth year over year for the last five years as a result of many awareness raising events, media and advertising efforts, and participation by our dedicated network of collection site operators encouraging their employees, customers, and communities to recycle their batteries. Pursuant to the requirements of the Manitoba Household Hazardous Material and Prescribed Material Stewardship Regulation, this five-year Product Stewardship Plan is being submitted for review and approval for Call2Recycle to continue as the battery stewardship program for the Province. This plan covers the five-year period from 2017 through 2021. It provides an outline of current program operations and our plans to further grow the program in Manitoba. During the course of this plan, Call2Recycle proposes to: • Increase consumer awareness of battery recycling from 77% to 85% • Increase incidence/frequency of battery recycling from 44% to 60% • Increase accessibility to recycling from the current 91% to 95% • Increase the battery collection target from 25% to 33% Continuous improvement is fundamental to the future success of the Call2Recycle program. As such, ongoing investment in research and development to enhance our collection and recycling infrastructure is essential. Performance measures and targets herein will be achieved through enhancing public awareness initiatives, increasing accessibility, leveraging partnerships with producers and collection organizations, transparent operational management, and continuing collaboration with the Province toward our shared goals. Every year a report will be provided to Manitoba Sustainable Development to review activities and performance. Call2Recycle has proven its ability to meet the requirements of a stewardship program for Manitoba Sustainable Development over the past years. Further, we are an ideal candidate to continue as the stewardship program because we are focused on overcoming any challenges present in the marketplace, and we continue to investigate and utilize new technologies and go- to-market strategies. We look forward to continued collaboration with Manitoba Sustainable Development and also the residents of the province to increase battery collections and recycling. 2
1. Plan Submission In keeping with the requirements of the Household Hazardous Material and Prescribed Material Stewardship Regulation (the “Regulation”) issued under The Waste Reduction and Prevention Act and the draft Guideline for stewardship programs issued in Manitoba, Call2Recycle Canada, Inc. has developed this five-year battery recycling plan renewal and is submitting it for approval to Manitoba Sustainable Development. 2. Call2Recycle Overview Call2Recycle Canada, Inc. is the Canadian arm of North America’s first and largest non-profit consumer battery stewardship organization. The program in both Canada and the United States was established to fulfill the product stewardship obligations for retailers and distributors of products, battery manufacturers, and manufacturers whose products contain batteries. From inception, the program has diverted more than 100 million kilograms of batteries and cellphones from the solid waste stream and established 30,000 collection sites across North America. Since 1997, Call2Recycle has operated a robust battery collection and recycling program across North America, and today works on behalf of more than 300 battery and product manufacturers and retailers. The program collects and recycles dry-cell batteries weighing less than five (5) kilograms from local governments, businesses, and consumers at no cost to them. Call2Recycle Canada is governed by a Canadian Board of Directors. Our network of public and private collection facilities, sorters, and processors ensures optimal efficiency, cost-effectiveness, and continued growth along with promoting ease and practicality of the program. Call2Recycle’s national reach minimizes confusion among consumers and reduces administrative red tape and redundancies for larger collection site operators. In order to be effective contributors to the cause of conservation and recovery, Call2Recycle routinely adopts best practices gleaned from its own research and from associate organizations both in Canada and internationally to increase collections. Promoting environmental sustainability across the country, the program meets Basel Action Network (BAN) e-Steward qualification standards, and is the first program of its kind to receive the Responsible Recycling Practices Standard (R2) certification. As a result, Call2Recycle is the preferred choice for product stewards and stakeholders including retailers, governments, stewardship organizations, associations, and NGOs. In 2011, the Manitoba Government approved Call2Recycle as the agency to meet producer obligations for household batteries. As required by the government we are submitting this five- year renewal plan for review and approval. This Product Stewardship Plan proposes to continue to build on the past success of the Call2Recycle program in Manitoba. 3
3. Collection System and Consumer Access
Call2Recycle operates a simple and highly efficient program. Our primary focus is to recycle
consumer batteries wherein 100% of batteries collected through our program are diverted from
landfill. The program is offered at no cost to consumers dropping off their batteries at our
collection sites and for those signing up as collection site partners.
The program collects batteries weighing up to five (5) kilograms from collection facilities located
across the province for consumer convenience. Batteries are shipped and sorted by chemistry,
then sent to processing partners where their component parts are extracted for reuse in such
products as new batteries, stainless steel alloy, and roadbed aggregate additives.
Applicable Products
Call2Recycle manages a recycling program for batteries which includes:
• Rechargeable and primary (single-use) battery chemistries
• Batteries, regardless of whether the battery is supplied as a stand-alone product or
embedded in a product
• Batteries generated by both consumers and those generated by private businesses and
other organizations
The Call2Recycle program accepts dry-cell batteries weighing less than five (5) kilograms each.
Below is a list of the battery chemistries we accept:
• Nickel Cadmium (Ni-Cd)
• Nickel Metal Hydride (Ni-MH)
• Lithium Ion (Li-Ion)
• Nickel Zinc (Ni-Zn)
• Lithium Primary
• Alkaline/Carbon Zinc (AA, AAA, 9V etc.)
(See Appendix A: Glossary for detailed definitions.)
Excluded Products
This stewardship plan does not include management of:
• Motive batteries 1
• Wet cell batteries
• Batteries weighing more than 5 kg
Orphaned/Free Rider Batteries
“Orphaned batteries” refers to batteries produced by a manufacturer that either no longer exists
or no longer produces batteries. “Free rider” refers to a battery manufacturer that is not a
registered steward with the Call2Recycle program. It should be noted that both “orphaned” and
“free rider” batteries are accepted by our program, and all batteries are diverted from landfill.
1
Managed under the Canadian Battery Association (CBA) program.
4Call2Recycle makes concerted efforts to register all battery manufacturers with the program to
eliminate “free rider” activity to ensure fairness in the market and compliance with the
Regulations. This ongoing process involves identifying potential “free riders” followed by a
series of recruitment actions including contacting the organization through letters and follow-up
phone calls. This formal undertaking is continued until the “free rider” signs on to the
Call2Recycle program or provides information that it has its own battery recycling program in
the Province. In the case that the organization either refuses to comply or is unresponsive to our
efforts and we have exhausted all avenues, we will seek assistance from Manitoba Sustainable
Development to bring these Stewards into compliance.
Collection System
Since 2011, Call2Recycle has laid the foundation for a robust battery collection and recycling
program serving Manitoba residents and businesses. In total, more than 325,000 kilograms of
batteries have been collected and diverted from the Manitoba waste stream. Call2Recycle will
continue to engage with and encourage residents to drop-off their batteries at one of our many
collection sites.
Call2Recycle collection facilities use one of two collection methods: the bulk program or the box
program. Our bulk program caters to facilities that generate large quantities of batteries for
recycling (250 kg minimum per shipment). The box program is designed for facilities that do not
generate large quantities of batteries in a short period of time or do not have the space to collect
bulk quantities. These facilities receive collection boxes free of charge. The box kits include
promotional material, plastic bags for battery terminal protection, and pre-paid shipping labels.
Each box holds up to 30 kilograms of batteries. Call2Recycle covers the cost of shipping for
both the bulk and box programs.
Any retailer, business, institution, or government entity which meets our collection site
requirements can participate as a drop-off location that is open to consumers (public site) or
collect batteries used internally (private site). Collection facilities are strategically located where
they are most likely to be used by consumers. Below are other considerations when adding
collection sites.
• Accessibility – To ensure an optimal number of collection sites available based on
geography, population density, and ease of access.
• Convenience – Facilitate ease of drop-off for consumers not only in urban areas, but rural
and remote communities by providing collection services at non-traditional drop-off
locations, holding recycling/round-up events, or through curbside battery collection.
• Cost-effectiveness – It is necessary to manage the program’s cost-to-serve for continued
growth and success.
• Environmental health and safety – Call2Recycle will work with companies that want to
enrol to promote environmental health and safety through battery recycling.
• Association to batteries – The likelihood that consumers will correlate batteries with the
location (e.g. an electronics store or recycling depots).
Collection locations that are available to Manitoba residents are listed on Call2Recycle’s
website and mobile phone locator. Residents can search by postal code or city and province to
find a battery collection location. In addition, they can select a geographical radius of up to
5150 km or even utilize the ‘Recycle on the Way’ feature that allows them to provide a start and
end address and then shows drop-off locations that are en route to their destination.
Research into domestic and international battery recycling programs shows no direct correlation
between changes in the number of collection sites and collection quantities. While there is a
need to increase the number of collection sites throughout the province, specifically in rural and
remote areas, Call2Recycle maintains a strong collection network, which currently offers
approximately 682 facilities throughout Manitoba.
For the duration of this plan Call2Recycle will take proactive measures to increase the number
of collection sites across the province specifically targeting municipalities, retailers, businesses,
and government agencies. We will also work to ensure that residents in urban, rural, and remote
areas (including First Nation communities) are served with a variety of battery recycling options
that range from permanent drop-off facilities, seasonal and event recycling, and direct door-to-
door (curbside). (For strategies see section 7. Consumer Awareness.)
Over the past years, Call2Recycle has been signing up various businesses as private collection
sites. As part of this renewal plan, efforts will continue to sign up these large volume generators
of spent batteries. They also have the option to use Municipal and Eco-Depots that are open to
the public. Depots are accessible by anyone, including large volume generators unless the
specific depot has chosen otherwise.
Northern and Remote Communities
Northern, remote and First Nations communities pose specific challenges to collecting not only
batteries for recycling, but all stewarded materials. These communities include geographic
areas not serviced by Canada Post, only accessible by plane or ice roads in winter, and low
population density spread out over a large area. Some of the issues in servicing these
communities include land transport accessibility, cost of service, infrastructure and willingness
of the locals to participate.
Call2Recycle will continue its collaboration with a variety of remote communities including First
Nations, municipal offices and provincial government. Joining forces with other Producer
Responsible Organizations (PROs) is another strategy to service remote communities by
pooling resources, sharing costs, and promoting and educating on recycling.
In the coming years Call2Recycle will continue to work with organizations such as Indigenous
and Northern Affairs Canada to participate in Environmental Awareness sessions with First
Nations communities. Call2Recycle will deliver presentations and educational material to create
awareness for our program among the First Nations chiefs and their communities. These types
of sessions provided insights in the various communities’ needs and preferences.
As early as 2017, Call2Recycle is planning to expand its efforts in northern
Manitoba. We will pilot a knowledge gathering project specifically
targeting First Nations communities to better understand their needs
and challenges.
6Consumer Accessibility
Call2Recycle has serviced the province of Manitoba for 20 years with its collection and recycling
program. At the time of this plan development, 91% of the Manitoba population has a drop off
location within 15 kilometers of their home. While coverage in many urban areas exceeds the 15
kilometers’ accessibility standard, improvements will be made to increase the number of
collection facilities and/or collection methods in non-urban communities as well as First Nations
communities.
By the end of 2021, Call2Recycle intends that 95% of the population will be within 15 kilometers
of a public collection site. (See section 10. Performance Measurement and Targets)
The following chart and map depict the current Call2Recycle collection network.
Manitoba Network Summary
Total Active Sites Active Public Sites Active Private Sites Accessibility
682 296 386 91%
In an effort to continually improve the convenience of its collection network within Manitoba,
Call2Recycle will evaluate the Manitoba network on a semi-annual basis and actively solicit
participation when and where needed.
Call2Recycle will also continue testing new methods for collecting batteries from Manitoba
residents to enhance access. For example, the ultimate in offering consumers accessibility is
curbside collection.
While curbside collection for recycling a variety of products has been around for decades, the
ability to collect batteries via curbside is new and in a testing phase. One challenge to
implementing curbside is that waste pick-up is becoming more automated and uses larger
equipment providing personnel a hands-free work environment with no necessity to get out of
their vehicle. Due to the nature of the size of batteries our program collects, and the fact that
some types may fall under hazardous waste, collections in the traditional manner (for example -
with other blue box materials) is not possible. However, Call2Recycle will endeavour to pilot a
curbside collection program to enhance consumer access.
7Manitoba Collection Network Map 8
4. Transportation and Sorting Call2Recycle will continue to utilize a variety of service providers including those for transportation and sorting. (See Appendix B: Call2Recycle Physical Flow Chart) In order to optimize participation, improve efficiency, and meet or exceed collection targets Call2Recycle is committed to an open, transparent, and fair process in selecting service providers. Call2Recycle operates in accordance with intra- and inter-provincial shipping and transportation standards established by Transport Canada, Environment Canada, and any other applicable provincial environment and transportation ministry approvals. Shipments transported internationally are manifested/shipped according to Environment Canada, Transport Canada, US Environmental Protection Agency, and the US Department of Transportation. Currently there are no sorters operating in Manitoba. Therefore, batteries collected through Call2Recycle in the province are sorted and consolidated in Ontario. While sorting batteries is currently done manually, new technologies are emerging and Call2Recycle remains at the forefront of investigating and utilizing these resources. Recently Call2Recycle contracted with a new sortation provider. This is the only operation in North America using automated sorting technology to separate batteries by chemistry. An artificially intelligent optical sortation device, the system sorts cylindrical batteries using a visible-light camera to determine brand and chemistry. Due to this automation, these types of batteries can now be sorted and separated at a rate of up to 1000 kg of batteries per hour. This is not only a more cost-effective method for sortation; it also increases Call2Recycle’s ability to handle greater volumes of collections and lessens the likelihood of human error. Once batteries are sorted according to chemistry, their weights are recorded, and they are readied for shipping to the appropriate recycling processor based on their chemical composition. 5. Processing of Products Call2Recycle is committed to meeting the highest global standards for safe and effective battery processing. We seek to maximize the amount of material that is captured from processing to direct it to secondary uses. Through the Call2Recycle program, all of the battery’s constituent parts are reclaimed and diverted from the waste stream. Different battery chemistries require different reclamation methods; therefore, Call2Recycle seeks partnerships with various processors to ensure optimal performance. We seek local processing partners wherever possible to reduce our transportation footprint. All of our processing facilities use the latest and proven-effective thermal, mechanical, or chemical processes to recover materials such as nickel, iron, lead, cadmium, and cobalt. Service partners are and will continue to be qualified by Call2Recycle under its rigorous selection practices. Processors are selected through a fair and transparent system that requires compliance with applicable environmental, health and safety, and transportation regulations. Processors will also be expected to have industry recognized certification(s) and audit processes in place. 9
Some selection practice examples are noted below:
• Review of the facility audit performed by CHWMEG (in past 2 years) or outside auditor
chosen by Call2Recycle to ensure the facility is in compliance with all regulatory and
performance requirements. CHWMEG, Inc. is a non-profit trade association comprised of
manufacturing and other "industrial" companies interested in efficiently managing the
waste management aspects of their environmental stewardship programs. Their programs
are based upon their potential environmental liability related to the wastes that are
inherently generated by their companies' manufacturing processes.
• Written policies outlining corporate commitment to environmental management and
continuous improvement.
• Complete tracking and documentation of materials in and out of facilities.
• Final destination receipt and disposal documentation/certification, downstream processing
material management, residual material management, and residual waste management.
In an added effort to ensure the highest standards, the Call2Recycle program itself also
undergoes inspections to maintain industry recognized certifications, like those listed below:
• Responsible Recycling (R2) 2013: This certifies that Call2Recycle’s management
practices are comprehensive; covering environmental, health and safety, and data
security practices.
• International Standardization Organization (ISO) 14001: This certifies Call2Recycle’s
Environmental Management Standards for the management of the collection, and the
distribution to downstream processors, for the recycling of batteries.
• Occupational Health and Safety Advisory Services (OHSAS) 18001: This certifies
Call2Recycle’s Occupational Health and Safety Management System for the management
of the collection, and the distribution to downstream processors, for the recycling of
batteries.
• Basel Action Network (BAN): Call2Recycle is the first battery recycling program to be
recognized as an e-Steward, by the Basel Action Network (BAN), for ensuring that the
battery and electronic waste (e-waste) that the program collects and recycles is not
dumped in developing countries, local landfills, or incinerators. Thus, certifying that the
Call2Recycle program adheres to the strictest social and environmental standards.
Call2Recycle regularly monitors the landscape to keep abreast of the activities, regulations, and
new capabilities within processing facilities both locally (unfortunately at this time there are no
processors in Manitoba) and nationally. We also commit to regularly reviewing processors to
ensure that they can demonstrate an ability to adapt to Call2Recycle’s program growth and
volume increases in recyclable materials.
106. Consumer Awareness - Education and Outreach Strategic Approach Call2Recycle will employ an aggressive education and program awareness building campaign over the course of this plan. Primarily focusing on Manitoba residents, we will enlist our collection network participants - retailers, businesses, and municipalities - to raise awareness, drive participation, and maximize collections. On a parallel track, Call2Recycle will implement a proactive program to reach key opinion leaders, stakeholders, and media outlets. This will be complemented by an integrated, multi-channel approach through traditional, non-traditional, and digital media, as well as sponsorships and partnerships to efficiently reach the defined target audiences and further battery diversion goals. While Call2Recycle operates a national program across Canada, it also appreciates the unique characteristics of individual provinces, its residents, and available communication channels. Knowing who to reach and how to reach them is critical to the success of any outreach and education plan. To that end, Call2Recycle will continue to engage in specific research to understand the nuances of the Manitoba market. (See Appendix C for Highlights of 2015 Ipsos Reid Research Summary and Learnings.) To ensure a successful education and awareness campaign, the marketing budget will support a range of new and recurring outreach and education efforts. We will monitor consumer behaviours, attitudes, and actions, and will evaluate programs against key metrics, including collection targets and collection network accessibility. Based on continued learnings and outcomes, strategies and plans will be adjusted accordingly. Objectives 1) Educate: Inform Manitoba residents that a free collection and recycling solution exists for consumer batteries and what types of batteries can be recycled. 2) Motivate: Inspire the audience to recognize the role they play — raising awareness of the importance of battery recycling. 3) Move to action: Demonstrate the accessibility of battery drop-off sites, and provide a range of opportunities to find collection locations via online, partner, and telephone locators. Target Audiences A. Manitoba Residents: - Consumers - Businesses B. Collection Network: - Public Site (collects directly from residents): Municipalities, Retailers, Communities - Private Site (internal collections): Solid Waste Facilities, Businesses 11
C. Stakeholders:
- Key Influencers (Local Government, Industry and Trade Associations, and
Non-Governmental Organizations – NGOs-)
- Battery Stewards
- Media, Experts, Influencers
Call2Recycle’s collection network - whether a public or private site - receive ongoing training
and support. Education is provided on how to participate as a collection site. Other materials are
designed to educate staff, and show how to promote collections to the public. A variety of
communication vehicles are used to increase consumer awareness on battery recycling at the
point of sale including posters, rack cards, bookmarks, promotional items, brochures, signage,
newsletters, email blasts, etc. For some examples of material visit
http://www.call2recycle.ca/downloads/
To further promote recycling of batteries, Call2Recycle requests that collection boxes are placed
in an area that is clear and visible. However, the decision on where to place collection
receptacles lies with the individual sites.
Below is an overview of the marketing plan in chart form.
Audience Strategies Campaigns/Tactics
A. Manitoba Residents & Businesses
Consumers Seasonal Campaigns: National & Local National: National Battery Day, Spring
Cleaning, Back to School, Daylight Saving,
Holiday
Local: Waste Reduction Week Library
Campaign, Winter Arena Campaign
Businesses Key Industry-focused Campaigns Campaigns targeted at Healthcare,
Hospitality, Education, Travel, Solid Waste
Facilities
B. Collection Network
Municipalities/ Campaigns for organizations who collect Depots: National Municipal Depot
Communities directly from residents at public and private Campaign
places Collection site Newsletter
Retailers Retail Campaigns
Retailers Newsletter
C. Stakeholders
Key Influencers Partnerships with Local Government, Association Partnerships: AMM, MARR
Industry and Trade Associations, Non- NGO Partnerships: Manitoba Eco-Network
Governmental Organizations Environmental Partnerships: Pride Manitoba
Stewards Activities focused on supporters and Stewards Newsletter
contributors to our program
Thought Leaders Programs targeting media, journalists, National and Local Media campaign
subject matter experts, key decision makers Focused events and conferences
127. Funding Structure On February 1, 2017, Call2Recycle implemented a new funding model. Advance notice of this program modification was provided to Manitoba Sustainable Development along with a stakeholder communication plan. The funding mechanism is a “fee per unit sold” model referred to as Environmental Handling Fees (EHFs). The fees themselves are set through a budgeting process and then reviewed and approved by the Call2Recycle Canada Board of Directors. Based on the number of units of batteries sold into Manitoba, Stewards report quantities sold into the Province at pre-set periods using an online system. Call2Recycle will continue to keep Manitoba Sustainable Development apprised of any upcoming changes pertaining to the Schedule of EHFs. EHFs are used as a means to fund the program including but not limited to communications, collections, processing, and administration. Call2Recycle's program budgeting follows the same structure as most other steward programs. Call2Recycle will ensure accurate Steward remittances through a system that could include periodic audits to verify compliance and completeness of reporting of EHFs. It is solely the decision of the individual Stewards whether or not to recover the EHFs paid into the program from consumers either through a separate invoice item or product price. No fees are or will be charged to consumers at the point of collection of spent batteries. The organization maintains a reserve fund, whose amount is determined by Call2Recycle Canada’s Board of Directors. This fund ensures the stability of the current program and any future financial obligations that may arise. Call2Recycle complies with all annual reporting requirements as stipulated by Manitoba Sustainable Development as per the Regulation. Our consolidated finances are audited annually by an independent third-party auditor, and the results are made public and provided to stakeholders. A report specific to the province is provided to Manitoba Sustainable Development annually. As stipulated in the Regulation, the report provides an account of activities in the Province as relates to the waste management of batteries, including but not limited to consumer outreach and education, and collection performance. Once approved the report is posted on the Manitoba page at call2recycle.ca/manitoba. In accordance with the requirements of the WRAP Act and the Regulation, Call2Recycle will remit annual payments to Manitoba Sustainable Development for the payment of salaries and other costs of government for the administration and enforcement of the WRAP Act and the Regulation for the duration of this plan. 13
8. Management of Environmental Impacts The Province abides by the pollution prevention hierarchy—reduce, reuse, and recycle— however, this hierarchy can be more difficult to apply to batteries than to other materials and products. Call2Recycle is not in a position to promote a reduction in the use of batteries, and reconditioning batteries for reuse can pose an unacceptable safety risk to consumers. Therefore, we do not support reconditioning batteries unless certain strict conditions pertaining to the reconditioning organization, the safety testing, and the proper labeling of reconditioned batteries are met. Recycling is the most viable means of keeping battery waste from entering landfills. The Call2Recycle program efficiently and cost-effectively recycles household batteries of all types, and no battery collected through our program goes to landfill. The reclaimed materials from the batteries we collect can be used in various products, such as new batteries, cookware, appliances, and hardware. Call2Recycle had been relying on a hazardous waste generator registration for the storage of waste rechargeable batteries and spent electronics that it handles, but there is no requirement to use a manifest or have individual collection sites licensed. The Province has replaced several of the relevant regulations under the Dangerous Goods Transportation Act with a new Hazardous Waste Regulation that came into force effective May 25, 2016 however it is not necessary to obtain any additional or amended permits for the Call2Recycle Canada program in its current form, as confirmed by the Environmental Approvals Branch of Manitoba Sustainable Department. Call2Recycle’s transportation and battery processing partners have passed a rigorous selection process to ensure that they comply with applicable environmental, health and safety, and transportation regulations. We continually monitor each processor to ensure competitive pricing and an ability to adapt to increases in volume. The following charts show the recycling efficiency rates (recovery rates) for the processors currently used by the Call2Recycle program and how the various materials are managed. 14
Recycling Efficiency Rates
Rechargeable Battery Chemistry Primary Chemistry
Battery Type NI-CD LI-ION NI-MH ALKALINE LITHIUM
Processor Inmetco Glencore Inmetco Inmetco Inmetco
% Material Recovered*
To Metals 50% 27% 57% 21% 0 to 50%
To co-product, aggregate 2% 0% 14% 1% 37%
To Cadmium 12% 0% 0% 0% 0%
To Secondary Recovery** 4% 0% 5% 57% 2%
Plastic Recovery or
12% 44% 10% 5% 2%
Reductant
Total Recovery 80% 71% 86% 84% 91%
All collected batteries are sent to sorters and processors in Canada and the U.S. (See Appendix
B: Physical Flow chart.) Each of these facilities uses thermal, mechanical, or chemical recovery
processes to reclaim materials such as nickel, iron, lead, cadmium, and cobalt, and prepare
them for use in new products such as new batteries, stainless steel alloy, and roadbed
aggregate additives. Some processes also recover plastic and other constituents.
Environmental Transparency and Accountability
Call2Recycle maintains a commitment to third-party audit of non-financial, material end-fates,
and downstream processes in accordance with Manitoba Sustainable Development’s
requirements, in order to ensure transparency and accountability to the government and to the
public.
9. Dispute Resolution
Call2Recycle has established written agreements with our Stewards (Membership and Proxy
Agreements – available at http://www.call2recycle.ca/resources-support-centre/) and service
providers (sortation and processing partners). Disputes with either of these groups follow a
similar process to ensure that there is a fair and equitable resolution. As a first step, once the
issue has been raised in writing, representatives from Call2Recycle and the other party will
attempt to resolve the issue within 30 days (or another mutually agreed upon timeframe). If we
cannot come to a resolution within the given timeframe, the two will select a mutually agreed
upon third party to arbitrate and settle the dispute with his/her decision.
1510. Performance Measurement and Targets
It is important to measure the success of a program and organization in order to improve its
performance and ensure accountability. In its original plan submission in 2010, Call2Recycle
provided Manitoba Sustainable Development with specific collection and recycling targets and
thereafter with an annual report on performance. With this plan renewal, the program
performance measures remain consistent. The projected new targets are based on the
learnings and growth within the province over the past five years. In reviewing performance,
both quantitative and qualitative measures are taken into consideration to allow for a full
evaluation of the battery stewardship program in Manitoba.
Accessibility
In 2016, 91% of Manitobans resided within 15 kilometres of a Call2Recycle drop-off site. By
2021, Call2Recycle will ensure that accessibility will reach 95%. Accessibility and convenience
is critical in driving recycling behaviour. By the end of 2021 the program will expand recycling
convenience beyond the traditional “brick and mortar” concept and work with municipal and
waste collectors to provide additional recycling services through events and/or curbside
collections.
As previously written, Call2Recycle will focus on alleviating the challenges of recycling in remote
and First Nations communities with a goal of increasing their accessibility to battery recycling.
While the methods may not be traditional drop-off locations, we will work with locals,
government and other PROs to provide services that are specific to their unique needs and that
are cost effective for the program.
A chart with the annual accessibility target is provided below.
2017 2018 2019 2020 2021
91% 92% 93% 94% 95%
Battery Sales and Collection Targets
Calculating the amount of batteries sold into Manitoba is problematic for two main reasons.
First, batteries are often sold through a complex sales chain, from manufacturer to battery‐
powered product manufacturer to wholesaler to distributor to retailer. Most battery stewards can
only estimate sales into Manitoba. Second, depending on the chemistry, a high percentage of
batteries are sold in or with a product, further complicating tracking, disposal, and recycling.
16The following market factors - outside of our control - also add to the challenges of calculating
battery sales.
1) Weight of certain battery chemistries sold into the market declines year over year - Heavier
battery chemistries, such as nickel cadmium, are being replace by lighter lithium ion
batteries. This will have implications on the overall battery weight sold into the market.
2) Life of a battery - Battery life is increasing which reduces the need to replace batteries as
frequently.
3) Type of battery - Products that currently require primary batteries will likely be replaced by
those that run on rechargeable batteries – both embedded and easily removable.
The below chart - from our original 2010 proposal plan - shows our best estimate of batteries
being sold into the Province for a five year time period.
Year 2011 2012 2013 2014 2015
Estimated kg 553,000 564,000 575,000 586,500 598,000
sold into
Manitoba Market
In order to provide our best estimate and projections for the Manitoba renewal plan,
Call2Recycle developed a new methodology for determining consumer battery sales into
Manitoba. This methodology utilized research from many sources to determine the amount of
consumer primary and rechargeable batteries that will be sold into the market (excluding large
format, industrial, and electric vehicle batteries).
Since batteries are increasingly being sold embedded into product categories that may or may
not be regulated, Call2Recycle partners with many organizations that collect devices with
batteries. However, not all of these batteries will make it to the recycling stream. This is
especially true for products that are not regulated. Therefore, the model for calculations was
adjusted to remove a percentage of batteries that won’t make it into the recycling stream.
When Call2Recycle brought forward its initial battery Product Stewardship Plan for 2011-2015,
we presented a collection target rate of 25% at the end of five years, which aligned with the
targets and results achieved by European countries operating similar programs. Although
collections continue to grow year over year in Manitoba, Call2Recycle fell short of achieving the
2015 target rates (it did not meet the target for primary batteries but it did come very close to the
target for rechargeable batteries).
17Call2Recycle Manitoba Annual Collections, 2011 - 2015
90000
Collections in Kilograms
67500
Rechargeables
45000
Single Use
Total
22500
0
2011 2012 2013 2014 2015
While changing market conditions (as stated above) add to the difficulty of estimating actual
sales into market, Call2Recycle will strive to achieve the targets as set out below. The targets
may at first glance seem modest but are in line with similar programs running in other regulated
provinces (British Columbia and Quebec). The targets also take into account Manitoba
specificities such as population density, urban/rural and remote location challenges.
After the Environmental Handling Fee funding structure is implemented under which Stewards
report actual batteries sold into the Province, there will be an adjustment to the sold into market
(in kg) and collection targets (in kg) as a percentage of sales. However, the collection target
amount (in %) will remain as shown below.
The plan goal is to attain a 33% collection rate of batteries that are sold into the Manitoba
market by the end of year five (2021). Call2Recycle will annually assess performance against
targets using pre-defined metrics and may adjust strategies if necessary. Any performance
deficiencies will be outlined in a remediation plan, including corrective and strategic actions.
Collection Targets
2017 2018 2019 2020 2021
Batteries Sold Into MB
613,000 617,000 621,000 625,000 630,000
(in kg)
Collection Targets
25% 27% 29% 31% 33%
(as a % of sales)
Collection Targets (in kg) 153,250 166,590 180,090 193,750 207,900
18Implementation Timeline
As outlined in the Education and Outreach section, seasonal and other promotions and events
will be ongoing through the renewal plan years. The number of initiatives will vary over the years
all focusing on accessibility, awareness and action. We will regularly meet with other provincial
PROs to identify opportunities for partnerships that promote stewardship programs.
Major initiatives to increase Accessibility, Awareness and Action
2017 - 2019
Consumer Education - through schools and libraries
Collection Methods - for example curbside pick up
Increasing Collections - from northern, remote and First Nations communities
For an overview of all targets included throughout this plan, see Appendix E for the Summary of
Performance Measures chart.
For an overview of stewardship plan requirements and location in this plan, see Appendix F for
the Stewardship Plan Reference chart.
11. Stakeholder Consultation
Prior to being submitted to Manitoba Sustainable Development, Call2Recycle presented its plan
for consultations from stakeholders and the general public using the following methods:
1) The plan was posted on Call2Recycle’s website on April 4, 2016
2) Information about the consultations was posted on call2recycle.ca/mbconsultations/
3) Consultation announcements and requests to participate were sent to more than 300
stakeholders
4) A webinar was held on April 21, 2016 at 2:00 pm EDT. The recording of the webinar was
subsequently posted on call2recycle.ca/mbconsultations/
5) Communications and inquiries regarding the renewal plan were carried out through email at
mbplan@call2recycle.ca and via phone by central Canada staff.
6) Frequently asked questions and answers relating to the renewal plan and consultations
were posted on our website and can be found in Appendix G.
During the consultation phase some questions about the program where asked (see Appendix
G) but no concerns about the program where raised.
Further public consultations may be undertaken by Manitoba Sustainable Development.
1912. Appendices
Appendix A: Glossary
The following is a glossary of key terms and definitions related to the products covered in this
plan.
TERM DEFINITION
Alkaline /Carbon Zinc A type of single-use battery (e.g., AA or AAA batteries).
A type of rechargeable battery. Li-Ion batteries are typically found in
Lithium Ion (Li-Ion) portable devices, such as cellular telephones, tablets, laptop computers,
and digital camcorders.
Lithium Metal/Lithium A type of single-use battery.
Nickel Cadmium A type of rechargeable battery. Ni-Cd can typically be found in cordless
(Ni-Cd) power tools, digital cameras, two-way radios, and cordless phones.
A type of rechargeable battery. Ni-MH can typically be found in cordless
Nickel Metal Hydride (Ni-MH)
power tools, digital cameras, two-way radios, and cordless phones.
A battery that cannot be recharged by the consumer (for example, but not
limited to, alkaline, Carbon Zinc, lithium and zinc-air commonly known as
Primary Battery
AA, AAA, 9V, D-cell, and button cell batteries). Also referred to as single-
use batteries.
A type of battery that is designed to be used for a longer period of time
than single-use and is capable of being recharged. It can also be referred
Rechargeable Battery
to as a “secondary” battery (for example but not limited to, Li-Ion, Ni-MH,
Ni-Cd).
Also referred to as primary batteries. A battery that cannot be recharged
Single-Use Battery by the consumer (for example, but not limited to, alkaline, lithium and zinc-
air commonly known as AA, AAA, 9V, D-cell, and button cell).
A type of single-use battery. These batteries can typically be found in
Zinc-air
small devices such as hearing aids.
20Appendix B: Physical Flow Chart 21
Appendix C: Highlights from Ipsos Reid Research - Oct 2015 • Eight in ten (77%) residents of Manitoba say that at least some kinds of household batteries can be recycled while one in five (19%) say they don’t know and 4% say no, they can’t be recycled. • Men (81%) are significantly more likely than women (74%) to believe that household batteries can be recycled. Women (22%) are much more likely than men (15%) to not know if household batteries can be recycled. • There is not much variation in responses by age, however, 18-34 year olds are slightly more likely than 35-54 year olds and residents 55+ to believe batteries can be recycled. • Looking at all batteries, nearly three in ten (28%) are recycled. A majority (56%) of Manitobans say they recycle none of their batteries, while 15% recycle all of them. Roughly one in three (35%) batteries are thrown out – in fact, two in ten (19%) residents throw all of their batteries in the garbage, no matter what kind of battery. • Most frequently, Manitoba residents have recycled their household batteries at a recycling depot or centre (37%), at a retailer (27%), and at work (24%). • No matter the gender, most Manitobans recycle at a recycling depot or centre, at a retailer, and at work. Men appear to be more likely to recycle at these locations. • 53% of Manitobans are saving their single-use batteries for a future recycling trip while 41% say it’s easier to throw away rechargeable batteries, and over 30% just do not know what to do with their used batteries. 22
Appendix D: Battery Stewards As at December 31, 2015 3M Personal Safety Division Canon USA Inc. Accell North America Casio America, Inc. Acco Brands Corporation Cell-Con Inc. Ace Hardware Corporation Chenzhou Grand-Pro Tech Co.,Ltd. Acer America Corporation Chervon Limited Advanced Battery Systems, Inc. Chrysler Canada Inc. Agilent Technologies Cisco Systems Inc. Allied Intl/Allied Tools Clean Republic SODO, LLC Alltrade Tools LLC Cleva North America/LawnMaster Alpha Source, Inc. CO-OP Atlantic Amax Products Coleman Company Amazon Corporate Express Amazon.com, Inc. Costco American Lawn Mower Co Couche Tard American Toppower CTE Energy Co., Ltd. Anton/Bauer Dantona Industries/ Ultralast APC - Schneider Electric Deere & Company (John Deere) Asus Computer International Delhaize America (Hannaford Avex Electronics Corporation Supermarkets) Baccus Global Dell Canada Inc. barnesandnoble.com, LLC Dell Inc. Batteries du Quebec Inc. Deltran USA LLC Battery Specialties Digi-Key Corporation Bayco Products DLG Power Battery (Shanghai) BCBGMAXAZRIA Co.,Ltd. Belkin International, Inc. Do It Best Best Buy Canada Dollar General Best Buy Co., Inc. Dollarama BionX International Dongguan Golden Cel Battery Co. Bissell Homecare, Inc. Dorcy International, Inc. Black & Decker Corporation Duracell Canada (P&G) BlackBerry Duracell/Div of P&G BMR Group Inc. Duracell/Gillette Company/Proctor & BMW Canada Inc. Gamble Bose Corporation Eaton Corporation Braun/P&G/Gillette Eco-Stream Canada Brother International Enerco Group Inc. Bushnell, Inc. Energizer Battery Manufacturing, Canac-Marquis Grenier Ltee. Inc. Canadian Tire Energizer Canada 23
Energy Sales House of Batteries EnerSys Delaware Inc. HTC (High Tech Computer) Epson America, Inc. Husqvarna AB Esselte Corporation Hyundai Auto Canada Corp. Eveready (Energizer) IDX System Technology Inc. Evergreen (C.P.) USA Inc. Illinois Tool Works Excell Battery Company (W) Indigo Books Inc. EZsmart Gutter Cleaner, LLC Industrial Battery Service Inc. Familiprix Ingersoll Rand Family Dollar Inspired Energy LLC FdK America Intec Industries Co. Ltd. Fedco Electronics, Inc. Intermetro Industries Corp. Ferno - Washington, Inc. Interstate Batteries Recycling, LLC Finish Thompson, Inc. Invacare Corporation Ford of Canada Invox Hardware Limited FujiFilm Holdings America Corp iRobot Corp. Garmin International, Inc. iTech GE Healthcare Canada, Inc. ITO Co., Ltd. General Motors Jean Coutu Group Inc. General Wireless Operations (Old Jiawei Technologies (USA) Ltd. R/S) JLG Industries Inc. Getac Inc. Jvckenwood USA Corp. Giant Tiger Stores Limited KAN Battery Co., Ltd. Gibson Innovations Karcher North America GiiNii Tech Corporation Keysight Technologies Global Technology Systems, Inc. Kia Canada Inc. Gold Peak Industries (NA), Inc. Kodak Canada GP Batteries International Limited Kwonnie Electrical Products, Ltd. GP Battery Marketing Inc. L'Image Home Products GRACO, Inc. Lasource Division Gestion Greatbatch Inc. Quemar Inc. Green Smoke Inc. Le Groupe Jean Coutu Groupe BMR Inc. Lego Group GS Battery (USA) Inc. Lego Systems Inc. Harris Corporation Lenmar Enterprises, Inc. Hasbro Lenovo Canada Inc. Hewlett Packard Lexel Battery Co Ltd. Hilti, Inc. LG Electronics MobileComm USA Hitachi Koki Canada Co. Loblaw Inc. Hitachi Koki USA Ltd. Logitech Inc. HOBBICO, Inc. Mag Instrument, Inc. The Home Depot Makita Canada, Inc. Home Hardware Makita USA HoMedics Mattel, Inc. Honeywell International Inc. Maxell Corporation of America 24
McKesson Canada Corporation ProTeam, Inc. McMahon Distributeur Inc. Pure Energy Meritool LLC Quality One Wireless Metabo Corporation Rapport, Inc. formerly Car-Go Metro Rayovac/Spectrum Brands Metro Richelieu Inc. Richpower Industries, Inc. Michael Stores Inc. Ridge Tool Company (RIDGID) Microsoft RiteAid Midland Radio Corporation RKI Instrument, Inc. Miller Mfg. Co. Robert Bosch Tool Corporation Milwaukee Electric Tool Corp. Rocket Batteries Canada Mitsubishi Motors of Canada Rona Inc. Motorola Mobility LLC Ronda Group Co., Ltd. MTD Products Inc. Royal Consumer Information Musco Products, Inc. myCharge Rozon Batteries Inc. National Battery RRC Power Solutions National Power Corp Sail Plein Air Inc. Neptune Technology Group Inc. Samsung Electronics Co. Netgear, Inc. SANYO Energy USA Corp. Nikon Canada Inc. Scosche Industries Nippon Primex Inc. Scotts Canada Ltd. Nissan Canada Inc. Sears Canada Nobil Instrument Inc. SEE CGREEN1 GREENSMOKE Normark Innovations Inc. Senco Products, Inc. Novatel Wireless Inc. Sensidyne LP NYCL Company, Inc. Sharp Electronic of Canada Ltd. Nylube Products Company LLC Shenzhen Jingkehui Electronic Co, O2COOL, LLC Ltd. Olympus America Inc. Shoppers Drugmart Inc. OOMA Inc. Sigma Corporation Oracle America, Inc. Snap-on Inc. Original Power Inc. Sobey’s Quebec Inc. Palladium Energy Sony Canada Panasonic Canada Inc. Sony Electronics, Inc. Panasonic Corporation Southern Telecom, Inc. Panasonic North America Inc. Southwick Technologies Inc. Pantech Co. Ltd. Southwire Company Pelican Products, Inc. Spectrum Brands Philips Consumer Lifestyle SRAM, LLC Plantronics, Inc. Stanley Black & Decker Corporation PLR IP Holdings, LLC (Polaroid) Staples Canada, Inc. Polycom, Inc. Star Micronics Co., Ltd. Positec Tool Corporation STIHL Incorporated PowerMax Battery USA Stihl Limited 25
StorTronics True Value Streamlight, Inc. TTEK Assemblies Inc. Summer Infant, Inc. UAP Inc. Surefire, LLC Ultralife Corporation Suzuki Canada Uniden America Corporation Tacony Corporation Uniprix Technical Power Systems Inc. Universal Power Group Techtronic Industries Co Ltd Varta Microbattery Inc. Techtronic Industries GmbH Venom Group International Test Rite Products Corp Vernier Software & Technology Texas Instruments Inc. Vibratex, Inc. The Source Vizio Inc. TNR Technical VTech Telecommunications Ltd. Toro Company Wacom Technology Corp. Toshiba America Walmart Canada Corporation Toyota Canada Inc. Water Pik Inc. Toys R Us Canada Ltd. Wohler USA Inc. Tractor Supply Zebra Technologies Transcosmos America Inc. Zippo Manufacturing Company Traxxas L.P. Trek Bicycle Corporation 26
Appendix E: Summary of Performance Measures
Annual Targets and Goals
Measures 2017 2018 2019 2020 2021
Accessibility - % of population
82% 84% 86% 88% 90%
within 15 km of collection site
Collections Targets - batteries to
be collected expressed as a
25% 27% 29% 31% 33%
percentage of what is sold into
the MB market
Conduct two (2) Omnibus Surveys per year to inform on awareness
Consumer Awareness
and incidence
Battery Recycling Awareness* 77% 79% 81% 83% 85%
Battery Recycling Incidence** 44% 48% 52% 56% 60%
Locator Searches*** 31,640 33,000 40,000 45,000 50,000
Reporting - Annual Reports
May 2018 May 2019 May 2020 May 2021 May 2022
(Date each year)
*Battery Recycling Awareness: # or % of residents aware that household batteries can be
recycled in Manitoba
**Battery Recycling Incidence: # or % of residents who have recycled their batteries in Manitoba
***Drop-off locator on call2recycle.ca: # of MB-based searches
27Appendix F: Stewardship Plan Reference
Required in Plan Location
A. Stewardship Plan
1 The establishment and administration of a waste reduction and Throughout Plan
prevention program for household hazardous material and prescribed
material
2 The appropriate management of household hazardous material and Throughout Plan
prescribed material according to guidelines established by the minister
3 A province-wide, convenient collection system for waste material Section 3
without user fees at the point of collection
4 A system for the payment of expenses incurred in the collection, Section 7
transportation, storage, processing and disposal of waste material in
connection with the waste reduction and prevention program
5 The orderly collection of revenue from program subscribers in balance Section 7
with expenses for the program
6 The establishment and administration of education activities for the Section 6
program
7 The establishment and administration of point-of-sale information for Section 3
the program
8 The payment of salaries and other costs for the administration and Section 7
enforcement of the regulation and the Act as it relates to household
hazardous material and prescribed material
9 On-going consultations with those who may be affected by the program, Section 11
including members of the public, in accordance with any consultation
guidelines the minister may establish
10 The Plan may also deal with research and development, training and Section 6
. education activities, as well as activities related to waste reduction or
pollution prevention. The minister may provide additional program
guidance to program operators.
B. Program Plan Evaluation
Proposed Plan shall demonstrate how:
1 The cost of managing designated waste materials is borne by the Section 7
stewards and users of the designated material rather than by the
taxpayer
2 The management of these materials is economically and Section 8
environmentally sustainable
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